Memorandum Findings of Fact and Opinion
The respondent determined an income tax deficiency of $48,415.97 for the year 1946. The sole issue is whether houses sold for profit during the year were property used in a trade or business as defined by section 117 (j) (1) of the Internal Revenue Code, or whether the property was held by the taxpayer primarily for sale to customers in the ordinary course of trade or business.
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